Deposing Cavalry on Where it Resides/Venue

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David A. Szwak
Posts: 1974
Joined: Thu Jul 13, 2006 11:19 pm

Deposing Cavalry on Where it Resides/Venue

Post by David A. Szwak »

Hey [[Debt Collection Defense Lawyer]],

I would like to schedule the deposition of your client for a date in the next two weeks to address the issues raised in the venue motion and to ask them about facts relevant to that motion. Please advise me where that deposition needs to be scheduled [city and state] and what date[s] you have available. Thanks.

The areas of inquiry will be:
Cavalry's debtors having addresses in Texas and in counties in the Eastern District of Texas;
Cavalry's revenues generated from debtors having addresses in Texas and in counties in the Eastern District of Texas;
Cavalry's business interests in Texas and in counties in the Eastern District of Texas;
Cavalry's business licenses in Texas;
Cavalry's debts held, as owner, assignee or contract collection, where the debtor resides in Texas and in counties in the Eastern District of Texas;
Cavalry's corporate structure;
Cavalry's affiliated companies;
Cavalry's ownership;
Cavalry's advertisements in Texas;
Cavalry's phone calls and letters directed to residents in Texas and in counties in the Eastern District of Texas;
Cavalry's filing of lawsuits in in Texas and in counties in the Eastern District of Texas;
Cavalry's shared revenues with affiliated/sister/parent entities/persons;
Cavalry's shared expenses/costs with affiliated/sister/parent entities/persons;
Cavalry's shared assets and managers/officers/directors with affiliated/sister/parent entities/persons;
Cavalry's revenues derived from consumers in Texas;
Cavalry's motion to dismiss filed in this lawsuit;
Cavalry's publications viewed in Texas which list its name and location, regardless of the form of media used;
A listing of each transaction or other business dealing Cavalry has had in Texas;
A listing and copy of each complaint, regulatory or in a lawsuit proceeding, arising from Cavalry's alleged interaction with a Texas-based consumer;
A copy of each Answer filed by Cavalry in a lawsuit filed against Cavalry in counties in the Eastern District of Texas.

We will issue a duces tecum in the notice paralleling the above areas of inquiry. Please advise. Thank you.

David A. Szwak
David Szwak
Chairman, Consumer Protection Section, Louisiana State Bar Association
Bodenheimer, Jones & Szwak
509 Market Street, 7th Floor
Mid South Tower
Shreveport, Louisiana 71101
318-221-6444
Fax 318-221-6555
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